Updated June 2026 · Reviewed by a Form 5472 specialist

The short answer
Key takeaways
Form 5472 is a two-page IRS information return with nine parts, currently the December 2025revision. It has a separate instructions PDF. Use the revision that matches your tax year, and always download both the form and instructions from IRS.gov before filing.
Form 5472 carries the official title “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.” It is authorized by Internal Revenue Code section 6038A and, for foreign corporations, section 6038C. The current release is the December 2025 revision, and the IRS publishes a separate instructions document — the form and its instructions are two different PDFs on IRS.gov.
Before you write a single number, do two things. First, obtain an EIN: a foreign-owned single-member LLC cannot file without one, and a non-resident without an SSN applies on Form SS-4 by fax or mail. Second, confirm you have the revision that matches your tax year. Filing a 2025 return on a 2023-revision form invites processing problems. The structure has stayed stable since the 2017 expansion to disregarded entities under Treasury Decision 9796, but the line numbering is occasionally renumbered, so the right PDF matters.
| Item | Detail |
|---|---|
| Form title | Information Return of a 25% Foreign-Owned U.S. Corporation |
| Current revision | December 2025 |
| Statute | IRC §6038A (and §6038C for foreign corporations) |
| Number of parts | 9 (Part I through Part IX) |
| Parts a typical SMLLC completes | I, II, III, V, VI |
| Filed with | Pro forma Form 1120 (for a disregarded entity) |
| Standard deadline | April 15 (October 15 with Form 7004) |
| Penalty if missing/incomplete | $25,000 per form, per year |
Source: IRS Form 5472 (Rev. December 2025); IRC §6038A. Verified June 2026.
Form 5472 has nine parts: Part I (reporting entity), Part II (25% foreign owner), Part III (related party), Part IV (monetary transactions), Part V (foreign-owned U.S. DE transactions), Part VI (nonmonetary), and Parts VII–IX (large-entity base-erosion items). A typical SMLLC fills five.
The fastest way to understand the form is to see all nine parts at once, then learn which ones apply to you. The single most useful fact for a founder-owned LLC: you complete only five of the nine parts. The rest exist for large multinational corporations and almost never touch a small foreign-owned LLC.
| Part | What it reports | SMLLC completes it? |
|---|---|---|
| Part I | The U.S. reporting corporation / LLC | Yes |
| Part II | The 25% foreign shareholder (the owner) | Yes |
| Part III | The related party transactions were with | Yes |
| Part IV | Monetary transactions (services, rent, royalties, interest) | Only if such transactions exist |
| Part V | Reportable transactions of a foreign-owned U.S. DE | Yes |
| Part VI | Nonmonetary and less-common transactions | Yes (if any apply) |
| Part VII | Additional information (member of group, gross receipts) | Usually a few checkboxes only |
| Part VIII | Cost sharing arrangements | No (large entities) |
| Part IX | Base erosion payments under §59A | No (entities over $500M receipts) |
Source: IRS Form 5472 (Rev. December 2025); IRC §6038A, §59A. Verified June 2026.
Note the split between Part IV and Part V. Both deal with money, but they serve different filers. Part IV is the monetary-transaction grid used by a reporting corporation that is not a disregarded entity. Part V is the dedicated section for a foreign-owned U.S. disregarded entity — your LLC. A capital contribution, a loan, and a distribution for an SMLLC all land in Part V, which is the part most founders get wrong.
Part I identifies the U.S. reporting entity. Enter the LLC's legal name, EIN on line 1b, U.S. mailing address, principal business activity and code, total assets, country of incorporation, and the date the entity was formed. Every line in Part I applies to a single-member LLC.
Part I is the identity block for your company. Unlike the later parts, you complete all of Part I — there is nothing optional here. Accuracy matters: the name and EIN you enter must match exactly what the IRS has on file from your SS-4, or the package can be rejected.
| Line | What to enter |
|---|---|
| 1a | Legal name of the reporting corporation (your LLC's full legal name) |
| 1b | Employer Identification Number (EIN) — required, no exceptions |
| 1c | Total assets of the entity at year-end (often a small or zero figure) |
| 1d | Principal business activity description (e.g., e-commerce, consulting) |
| 1e | Principal business activity code (the 6-digit NAICS-style code) |
| 1f | Total value of gross payments made or received (reportable transactions) |
| 1g | Total number of Forms 5472 filed for the tax year |
| 1h | Total value of gross payments for all Forms 5472 filed |
| U.S. address | The LLC's U.S. mailing address (a registered-agent or office address) |
| Country / date | Country of incorporation and date the entity was formed |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part I. Verified June 2026.
Line 1b (the EIN) is the most common stumbling block, because many founders attempt to file before they have an EIN. You cannot. Lines 1g and 1h also confuse people: if you file just one Form 5472, line 1g is simply 1, and line 1h equals the total payments on that single form. Total assets on line 1c is frequently $0 for a dormant or startup LLC — that is acceptable, but it must reflect reality.
Part II identifies the 25% foreign shareholder — your foreign owner. Enter the owner's name, address, country of citizenship, country under whose laws they file or are organized, and their foreign tax identification number. For a 100%-owned SMLLC, the owner is you.
Part II describes the direct 25% foreign shareholder, and (if different) the ultimate indirect owner. A “25% foreign shareholder” is any non-U.S. person owning at least 25% of the entity by vote or value. For the classic founder LLC owned 100% by one non-resident, the 25% foreign shareholder is simply that founder.
| Field | What to enter |
|---|---|
| Name | Full legal name of the foreign owner (individual or entity) |
| Address | The owner's foreign home or registered address |
| U.S. identifying number | SSN/ITIN if the owner has one; otherwise leave blank |
| Reference ID number | An internal reference ID if the owner has no U.S. TIN |
| Foreign tax ID number (FTIN) | The owner's tax ID in their home country, if any |
| Country of citizenship | The individual owner's country of citizenship |
| Country of organization | For an entity owner, the country under whose laws it is organized |
| Country filing tax return | The country where the owner files an income tax return |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part II. Verified June 2026.
Most non-resident founders have no U.S. identifying number, which is normal — you are not required to obtain an ITIN just to file Form 5472. In that case you provide a reference ID number(any consistent identifier you assign) and your home-country foreign tax ID if you have one. The point of Part II is simply for the IRS to know exactly who controls the U.S. entity.
Part III identifies the related party the reportable transactions occurred with. Enter the related party's name, address, identifying numbers, country of organization, and the nature of the relationship. For a single-owner LLC, the related party is normally the foreign owner from Part II.
Part III names the related party— the person or company on the other side of every reportable transaction. A “related party” includes the 25% foreign shareholder and any person related to that shareholder under IRC sections 267(b) and 707(b)(1), as well as parties related under section 482. For the typical single-owner LLC, the related party in Part III is the same personnamed in Part II, because the founder both owns the LLC and is the one moving money in and out of it.
| Field | What to enter |
|---|---|
| Name of related party | The person/entity the transactions were with (often the owner) |
| Relationship | Check whether the related party is a foreign person and the relationship type |
| Principal business activity / code | The related party's business activity and code |
| U.S. identifying number | If the related party has an SSN/ITIN/EIN |
| Reference ID / FTIN | A reference ID and/or the related party's foreign tax ID |
| Country of organization / citizenship | Where the related party is organized or a citizen of |
| Country filing income tax return | Where the related party files a return |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part III; IRC §267(b), §707(b)(1). Verified June 2026.
If the LLC transacted with more than one related foreign party — say, your personal account and a separate foreign company you also own — you file a separate Form 5472 for each related party, and each form repeats Parts I and II while changing Part III. All of them attach to the single pro forma Form 1120.
Part IV reports monetary transactions — amounts paid or received for services, rent, royalties, interest, commissions, sales, and purchases — with a foreign related party. A foreign-owned disregarded entity generally uses Part V instead, so most single-member LLCs leave Part IV blank.
Part IV is the detailed monetary-transaction grid. It lists categories such as sales of inventory, rents, royalties, interest, premiums, commissions, and amounts paid for services, with separate lines for amounts paid to and received from the related party. This is the part used by a reporting corporation that is a real corporation — not a disregarded entity.
For a foreign-owned U.S. disregarded entity, the IRS instructions direct you to report the entity's reportable transactions in Part V rather than Part IV. So a classic SMLLC whose only dealings are funding, loans, and distributions with its owner will typically leave Part IV blankand complete Part V. Part IV becomes relevant only if the LLC genuinely paid or received money for things like services or royalties from a related foreign party in a way the instructions assign there.
| Category | Example for a small LLC |
|---|---|
| Sales / purchases of stock in trade (inventory) | Buying goods from a related foreign supplier |
| Rents / royalties paid or received | Royalty paid to a foreign owner for a trademark |
| Amounts paid for services | Management fee paid to a related foreign company |
| Interest paid or received | Interest on a loan from the foreign owner |
| Commissions paid or received | Sales commission to a related party |
| Other amounts | Any other monetary item not captured above |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part IV. Verified June 2026.
Part V is where a foreign-owned U.S. disregarded entity reports every reportable transaction with its owner — capital contributions, loans, loan repayments, and distributions. This is the most important part for a single-member LLC, because funding the LLC alone makes the transaction reportable.
Part V exists specifically because of the 2017 expansion under T.D. 9796. Before then, a disregarded entity had no Form 5472 obligation. Now a foreign-owned U.S. DE must report all of its reportable transactions, and Part V is the dedicated home for them. This is the part founders most often complete incorrectly or omit entirely.
The critical concept: the trigger is a transaction, not income. The day you wire money from your personal account to fund the LLC, you create a reportable contribution. When the LLC pays you back or sends you a distribution, those are reportable too. That is why virtually every foreign-owned single-member LLC has at least one reportable transaction in its first year and almost all must file.
| Transaction | Goes on Part V? | Notes |
|---|---|---|
| Capital contribution (funding the LLC) | Yes | Reportable even with zero revenue |
| Loan from the owner to the LLC | Yes | Report the amount advanced |
| Loan repayment from the LLC to the owner | Yes | Report the amount repaid |
| Distribution from the LLC to the owner | Yes | Money taken out by the owner |
| Owner paying the LLC's formation/state fee | Yes | An indirect contribution counts |
| Pure third-party U.S. sales (no owner involved) | Not by itself | Needs an owner/related-party leg |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part V; T.D. 9796. Verified June 2026.
Report the dollar amount of each category for the year. If you contributed $10,000 to start the LLC and later took a $2,000 distribution, those amounts appear in Part V. There is no de minimis exception — a single $50 funding transfer is still a reportable transaction.
Part VI reports nonmonetary and less-common transactionswith a related party that the monetary parts do not capture — for example, transferring property into the LLC rather than cash. Many single-member LLCs have nothing to enter here and describe “none” if no such transaction occurred.
Part VI is a catch-all for transactions that are not straightforward cash movements. If you contributed equipment, intellectual property, or other property to the LLC instead of money, or there was a nonmonetary exchange with the related party, you describe it here. The instructions ask you to provide a description and the reasonable estimated fair market value of the transaction.
| Nonmonetary item | Reportable in Part VI? |
|---|---|
| Contributing equipment or inventory (not cash) to the LLC | Yes |
| Transferring intellectual property to the LLC | Yes |
| A barter or in-kind exchange with the related party | Yes |
| A cash-only contribution | No — that belongs in Part V |
| No nonmonetary dealings at all | Nothing to report |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Part VI. Verified June 2026.
For most founders who simply wired cash to start the LLC, Part VI has nothing to report — the cash contribution belongs in Part V. Part VI matters when value moved in a form other than money.
Rarely. Part VII collects additional information (group membership, gross receipts) and may need a few checkboxes. Parts VIII and IX cover cost-sharing arrangements and base-erosion payments under IRC section 59A — these apply to entities with over $500 million in receipts, not small LLCs.
The final three parts exist for large multinational corporations and are a frequent source of needless worry for small founders. Here is how they actually break down:
| Part | What it covers | Applies to a small LLC? |
|---|---|---|
| Part VII | Additional information: group membership, gross receipts, ownership checkboxes | Usually only a few checkboxes |
| Part VIII | Cost sharing arrangements between related parties | No |
| Part IX | Base erosion payments and the BEAT under IRC §59A | No — for entities over $500M gross receipts |
Source: IRS Instructions for Form 5472 (Rev. December 2025), Parts VII–IX; IRC §59A. Verified June 2026.
The base erosion and anti-abuse tax (BEAT) in Part IX targets corporations with average annual gross receipts of at least $500 million over a three-year period. A founder-owned LLC with a few thousand dollars of activity is many orders of magnitude below that threshold, so Parts VIII and IX stay blank. Part VII may require checking a box or two (for example, indicating the entity is not part of a controlled group), but it involves no complex computation for a small LLC.
Get an EIN and the December 2025 form, complete Part I (the LLC), Part II (the owner), Part III (the related party), Part V (DE transactions), and Part VI (nonmonetary), attach it to a pro forma Form 1120 marked “Foreign-owned U.S. DE,” then mail or fax it by April 15.
Here is the full completion flow for a foreign-owned single-member LLC, in order. Each step maps directly to the parts explained above.
| Step | Action |
|---|---|
| 1 | Get an EIN (Form SS-4) and download the December 2025 form + instructions from IRS.gov |
| 2 | Complete Part I — LLC name, EIN (line 1b), address, business activity, total assets |
| 3 | Complete Part II — the 25% foreign owner's name, country, and tax ID |
| 4 | Complete Part III — the related party (usually the same owner) |
| 5 | Complete Part V — contributions, loans, repayments, distributions (the key part) |
| 6 | Complete Part VI — any nonmonetary transactions (often none) |
| 7 | Attach to a pro forma Form 1120 marked 'Foreign-owned U.S. DE' |
| 8 | Mail to P.O. Box 149342, Austin, TX 78714-9342, or fax 855-887-7737 by April 15 |
Source: IRS Instructions for Form 5472 (Rev. December 2025); filing address for foreign-owned U.S. DEs. Verified June 2026.
This is the step where the most damage is done: a foreign-owned disregarded entity cannot e-file. There is no e-file path for this package. The only two accepted methods are mail to the Austin address and fax to 855-887-7737. Keep a certified-mail receipt or a fax confirmation as dated proof, because timely filing is your only defense against the $25,000 penalty.
If you cannot finish by April 15, file Form 7004 by April 15 to extend the filing deadline to October 15. The extension moves only the filing date; a disregarded entity owes no entity-level tax, so there is nothing else to extend.
Form 5472 cannot be filed alone. A foreign-owned U.S. DE completes only the identification block of Form 1120 (name, address, EIN, formation date), writes “Foreign-owned U.S. DE” across the top, leaves all income and tax lines blank, and attaches Form 5472 behind it.
The regulations require Form 5472 to be attached to an income-tax return, and the only return available to a disregarded entity is a pro forma Form 1120. “Pro forma” means a shell return — a cover sheet, not a tax computation. You complete the top identification block of page 1 and nothing else.
| 1120 area | Do what? |
|---|---|
| Top margin | Write 'Foreign-owned U.S. DE' |
| Name / address / EIN block | Complete fully |
| Date incorporated / total assets | Complete |
| Income lines (1–11) | Leave blank |
| Deduction lines (12–29) | Leave blank |
| Tax and payments (Schedule J, etc.) | Leave blank |
| Form 5472 | Attach behind the pro forma 1120 |
Source: IRS Instructions for Form 5472 / Form 1120, foreign-owned U.S. DE filing. Verified June 2026.
If the LLC has more than one related party, attach one Form 5472 per related party to the single pro forma 1120. A typical single-owner LLC files exactly one pro forma 1120 with one Form 5472 stapled behind it.
The top mistakes are: leaving the EIN (line 1b) blank, putting contributions on Part IV instead of Part V, forgetting the pro forma Form 1120, trying to e-file, and missing April 15. A substantially incomplete form is treated as not filed and carries the full $25,000 penalty.
Because a substantially incomplete Form 5472 is treated as not filed, line-level errors carry the same $25,000 penalty as never filing at all. These are the mistakes that cause the most trouble.
| Mistake | Part / line | Fix |
|---|---|---|
| Filing without an EIN | Part I, line 1b | Get an EIN on Form SS-4 first |
| Putting a contribution in Part IV | Part IV vs Part V | A DE reports contributions in Part V |
| Skipping the pro forma 1120 | Cover return | Form 5472 must attach to a pro forma 1120 |
| Trying to e-file | Filing method | Mail or fax only — no e-file for a DE |
| Leaving Part V blank when funded | Part V | Funding the LLC is reportable; report it |
| Missing April 15 | Deadline | File Form 7004 to extend to October 15 |
| No proof of filing | Submission | Use certified mail or keep the fax confirmation |
Source: form5472.tax filing experience; IRS Instructions for Form 5472. Verified June 2026.
Every one of these is preventable. A specialist who completes Form 5472 line by line every day catches all of them, which is why foreign founders pay a flat $299 rather than risk a $25,000 penalty — and far less than the $547 charged by form5472.online or the $1,999/year charged by doola for the same filing.
Form 5472 and the pro forma 1120, filled in line by line, reviewed, and filed for a flat $299. Or message us first — we answer every question.